Response to public consultation on EDPB draft guidelines on territorial scope

DIGITALEUROPE welcomes the European Data Protection Board’s (EDPB) draft guidelines on the GDPR’s territorial scope. We believe that the guidelines will be very relevant for controllers and processors operating both within and outside the EU.

In included sections, we highlight areas where the draft guidelines could further consider the complexities of controller-processor relationships that don’t fall squarely within the remit of the GDPR. This will increase clarity and legal certainty along with the draft guidelines’ consideration of existing case law from the Court of Justice of the European Union.